Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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HC held that preprinted waiver forms used by Customs Department cannot be considered valid oral show cause notices under Section 124 of the Customs Act. The court directed that passengers must be properly informed about applicable provisions regarding oral SCNs, and personal hearing notices must be provided via WhatsApp, email, and through authorized signatories even if notice is waived. For foreign travelers, personal effects including jewelry declared in the 'Red Channel' with undertaking to re-export should not be detained. The court ordered the Customs Department to conduct sensitization initiatives to prevent unnecessary detention of personal jewelry worn by travelers, and directed the development of a Standard Operating Procedure until the Baggage Rules can be amended to align with current economic realities.
HC held that preprinted waiver forms used by Customs Department cannot be considered valid oral show cause notices under Section 124 of the Customs Act. The court directed that passengers must be properly informed about applicable provisions regarding oral SCNs, and personal hearing notices must be provided via WhatsApp, email, and through authorized signatories even if notice is waived. For foreign travelers, personal effects including jewelry declared in the 'Red Channel' with undertaking to re-export should not be detained. The court ordered the Customs Department to conduct sensitization initiatives to prevent unnecessary detention of personal jewelry worn by travelers, and directed the development of a Standard Operating Procedure until the Baggage Rules can be amended to align with current economic realities.
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